A six-step pre-award checklist.

The same federal contractor reviewed by two different analysts will get two different answers if neither is following a fixed process. The variance is not analyst skill; it is the absence of an explicit workflow. A checklist solves that by making the steps explicit, the order fixed, and the source of evidence consistent.

A defensible diligence record is one another reviewer can re-run and arrive at the same conclusion. That requires (a) the same sources queried in the same order, (b) the same identity anchor, and (c) the same disposition rules for ambiguous evidence. The six steps below are designed to satisfy all three.

Step 1

Confirm the exact legal entity. Start with the legal name, UEI, or CAGE code. If the identity is wrong, every other check is misleading. The rest of the checklist anchors to the resolved SAM.gov record.

Step 2

Verify SAM.gov registration and exclusion status. Confirm that the entity is active in sam.gov and that the record does not show exclusions. Active with exclusions disqualifies; expired blocks new awards. See the SAM.gov check guide.

Step 3

Review labor and enforcement history. Pull DOL Wage and Hour Division and OSHA enforcement. Willful and repeat-violator flags signal patterns of operational risk that go beyond the headline violation count.

Step 4

Check federal performance context. Use www.usaspending.gov to see whether the vendor has recent federal award history. A first-time federal contractor is not disqualifying, but it does change how much weight to give their capability statements.

Step 5

Screen hardware and supply-chain exposure. If the procurement involves hardware or connected devices, run a Section 889 (FAR 52.204-25) hardware screen and verify the FAR 52.204-26 representation has been completed honestly.

Step 6

Document what still needs manual review. Automated screening is the first pass. Keep a running list of open items that need analyst, compliance, or counsel review before the file is closed.

Patterns that show up repeatedly in pre-award reviews and that should slow the workflow:

• Name mismatch between marketing brand and SAM.gov record. The SAM record is filed under the legal entity. A capability statement may use a DBA or trade name that doesn't resolve cleanly. Trace it to the UEI before continuing.
• Expired or incomplete federal registration. Any vendor claiming award-readiness with an expired SAM should have a renewal in flight. If they don't, the timeline is at risk.
• Repeated labor or workplace safety issues. A single OSHA citation is normal noise; a pattern across years across multiple sites is a responsibility concern.
• No meaningful federal performance history despite stated public-sector experience. Capability statements describing "extensive federal experience" should match USAspending records.
• Hardware sourcing that creates Section 889 follow-up work late in the cycle. Discovering a Hikvision camera in a subcontractor's shipment after award is the most expensive way to find out about Part B.
• Recent ownership change inconsistent with the capability statement. A company that was acquired six months ago may have a substantially different leadership team than the one named in their proposal.

The acronyms that come up in every pre-award review:

UEI

Unique Entity Identifier. 12-character alphanumeric assigned by sam.gov. Replaced DUNS in April 2022.

CAGE

Commercial and Government Entity code. 5-character. Assigned by the Defense Logistics Agency. Identifies a specific physical location.

NAICS

North American Industry Classification System. The federal industry-classification taxonomy. Used to determine small-business size standards.

PSC

Product and Service Code. The federal classification taxonomy for what is being bought. PSC codes 10-19 cover weapons, ordnance, and aerospace.

FAR

Federal Acquisition Regulation. The primary regulation governing executive-branch federal procurement.

DFARS

Defense Federal Acquisition Regulation Supplement. DoD-specific FAR addendum.

EIN / TIN

Employer Identification Number / Taxpayer Identification Number. Federal tax IDs assigned by the IRS.

EPLS

Excluded Parties List System. Retired; exclusion data now lives in SAM.gov.

FAPIIS

Federal Awardee Performance and Integrity Information System. Performance data updated semi-annually; publicly available for entries posted after April 15, 2011 (FAR 52.209-9).

DiligenceDesk runs steps 1 through 5 of this checklist automatically in a single search. The sixth step (documenting what still needs manual review) is the responsibility of the analyst running the audit.

The output is exportable as PDF or CSV so the diligence record can attach to the procurement file. The verdict is deterministic so the same vendor reviewed by two different analysts on the same day produces the same evidence. See the methodology page for how the verdict ladder weighs the evidence.